It’s Official—The UAS IPP Will End in Two Months
BY Zacc Dukowitz13 August 2020
Well folks, it’s official—the UAS Integration Pilot Program (IPP) will end in October.
We first heard about the IPP ending from Chris Korody of the Drone Business Center.
We reached out to the FAA for confirmation and they told us that yes, after the three year period mandated by the original IPP memorandum issued by the White House, the program would be coming to a close.
But when we read the memorandum, we noticed that it doesn’t require the program to end. Rather, it states: “The Program shall terminate 3 years from the date of this memorandum, unless extended by the Secretary.” (The italics are ours.)
So did the IPP achieve its goals? And why isn’t it being extended?
The UAS IPP and Its Goals
Before we address those questions, let’s do a quick refresh on the UAS IPP and its primary goals.
The UAS Integration Pilot Program (UAS IPP) is a federal program created in 2017 with the explicit goal of crafting “new rules that support more complex low-altitude operations by:
- Identifying ways to balance local and national interests related to drone integration
- Improving communications with local, state and tribal jurisdictions
- Addressing security and privacy risks
- Accelerating the approval of operations that currently require special authorizations“
In order to tackle these goals, in 2017 the FAA approved ten different IPP programs throughout the U.S. These programs have been run by local authorities, including state, municipal, and tribal governments, in partnership with private companies.
A map showing the locations of the ten IPP sites (see the FAA’s interactive map here)
These programs all set out to test various types of Part 107-prohibited operations. At least five of them successfully received waivers for these operations, including:
- Flying BVLOS (Beyond Visual Line of Sight) for consumer deliveries (Virginia IPP)
- Flying BVLOS for medical deliveries (North Carolina DOT IPP and Reno, NV IPP)
- Flying BVLOS for work in law enforcement (San Diego IPP)
- Flying both at night and BVLOS to survey pipelines (University of Alaska—Fairbanks IPP)
[Related reading: A Look at the 10 UAS IPP Winners—Who They Are and What They Plan to Do]
Did the IPP Achieve Its Goals?
When you boil it down, the IPP had just one explicit goal, which was to assist in crafting “new rules that support more complex low-altitude operations.”
If we limit our evaluation of the IPP’s success strictly to a consideration of whether the IPP has helped the FAA craft new rules that meet these criteria, here are the relevant rules that have been proposed within the last three years:
- NPRM* 1: Operation of Small Unmanned Aircraft Systems over People (Comment period was 3/13/2019—4/15/2019)
- NPRM 2: Safe and Secure Operations of Small Unmanned Aircraft Systems (Comment period was 3/13/2019—4/15/2019)
- NPRM 3: Remote Identification of Unmanned Aircraft Systems (Comment period was 12/31/2019—3/2/2020)
- NPRM 4: Type Certification of Unmanned Aircraft Systems (Comment period was 2/3/2020—3/4/2020)
[*What is an NPRM? In order to make new rules, the FAA must first present a Notice of Proposed Rulemaking, or NPRM. NPRMs are issued by law when an independent agency of the U.S. government wishes to make changes to its rules.]
When we review them, these four proposed rules do represent significant—though admittedly slow and incremental—advances toward the creation of “new rules that support more complex low-altitude operations.”
The first NPRM contains the biggest potential change to the Part 107 rules—a proposal to allow drone flights both at night and over people.
The second and third NPRMs (covering Safe & Secure Operations and Remote ID) start to lay out the groundwork for Unmanned Traffic Management, which could be seen as a precursor to allowing for BVLOS flights.
The fourth rule could also be seen as laying the groundwork for a novel path to allowing BVLOS for drone delivery and other types of use cases, by certifying drones for these operations instead of individuals or organizations.
However, despite the promise we see in these four NPRMs for a future in which BVLOS, night flying, and flights over people are all permitted, the reality is that none of these rules have been implemented—that is, none of the Part 107 rules have changed as a result of the IPP.
At least not yet, anyway.
Waivers and Part 135 Certification for Drone Delivery
But even if the Part 107 rules haven’t changed, since the IPP began the FAA has issued a lot more waivers for operations like flying at night, BVLOS, and flying over people.
And IPP partners have been some of the first to receive sweeping BVLOS waivers. This review we did of the progress of IPP sites last year shows that five of the ten sites had received some kind of uncommon or novel waiver to allow them to operate outside of the Part 107 rules (it’s noteworthy that all five involve BVLOS in some way, as reflected in the list of operations for which they received waivers shown above).
Photo credit: Wing
During the IPP’s operation, the FAA has also allowed companies to begin offering drone delivery via Part 135 certification, essentially creating a new regulatory framework for these types of drone operations.
To date, the only two companies to receive this special certification are Alphabet’s Wing and UPS’s Flight Forward, both of which are IPP partners and relied on tests conducted through the IPP for their successful applications.
Taking this progress into consideration, it does look like the FAA is moving forward toward allowing complex sUAS operations, just at a slower rate than many would like to see.
What the FAA Says about the IPP’s Success
We asked the FAA to comment on the IPP’s accomplishments, and this is the statement it gave us:
The UAS/IPP has made significant progress in achieving its stated goals. Those goals include fostering innovation, advancing the safe integration of drones into our nation’s airspace, and ensuring U.S. global leadership in the emerging UAS industry. Under the IPP, the FAA’s partnerships with state, local, and tribal governments have yielded valuable operational data and insight into public engagement around UAS. These partnerships will help advance policy development and enable more complex, routine drone operations. Although the IPP ends in October 2020, the work continues. More work is needed to find adaptable solutions to address the technical challenges associated with beyond visual line-of-sight operations and detect-and-avoid capabilities. In addition, more information is needed on the economic and societal benefits of UAS and the best practices for community engagement. The FAA looks forward to advancing UAS integration with its IPP partners through existing partnership mechanisms or through new collaborative public-private partnerships.
– The FAA
We’ll admit that we were hoping to see a list of concrete accomplishments—all the waivers granted, all the tests conducted, and other key data collected—but it could be that this information is still being collected for a final report that will be issued after the program officially ends in October.
So Why Isn’t the Program Being Extended?
A requirement laid out in the presidential memorandum that established the UAS IPP is that the Secretary of Transportation must send “an annual report to the President setting forth the Secretary’s interim findings and conclusions concerning the Program.”
But these annual reports do not seem to have been made public, which makes it hard to say why exactly the program isn’t being extended.
The lack of comprehensive reporting on the IPP was underscored in a recent open letter sent to Secretary of Transportation Elaine Chao by the Small UAV Coalition:
As the IPP comes to a close, the Coalition urges the DOT and FAA to prepare a report that not only summarizes the UAS operations conducted under the IPP, but also addresses how the IPP met its stated objectives and what actions will be taken from the lessons learned from the IPP.
– The Small UAV Coalition
Another stipulation in the IPP’s presidential memorandum is for the Secretary of Transportation to submit a final report with findings and conclusions from the program within 90 days after it has ended.
We hope that this report will be made public, and that the FAA will use its findings to transition from proposing new rules about BVLOS and other prohibited operations, to implementing them.
What do you think—was the IPP a success? Share your thoughts in this thread on the UAV Coach community forum.